Hey guys, it's sasha, there have been a lot of news coming out of trading into one two over the past couple of days, and most of this news has been really good, except for two really major problems that i'm gon na get to in just a second Trading 202 have done another huge update on the terms conditions just this morning, which is why i'm making this video - and i will tell you exactly what has changed. They've also secured funding opened up new account registrations in europe a few hours ago and it looks like they may be, opening up to new accounts in the uk very soon as well, but first, let's get started with most important bit the new terms and conditions now Trading two one two have updated their t's and cs quite a few times in the last few months. The last two times there were major updates. I made videos and unfortunately, those videos were not very kind.

They weren't very positive because some of the changes were really quite bad and when i read the updates this morning, i was really surprised. Trading 212 seemed to have gone and fixed a whole load of issues that i pointed out in those videos wow now i know that they have far better things to do than watch youtube, so this is a complete coincidence right. Well, i am very happy that they're gon na fix those issues so before we get to the bad stuff. Here are the good changes in march trading to want to introduce clause 10.19, which stated that trading 212 may reasonably at its sole, reasonable discretion, introduce or amend the minimum or maximum size of any order in any investment, and this was very concerning here is what i Said about it at the time does this clause in this wording mean that at its sole reasonable discretion, as it puts it, trading torture can amend the minimum and maximum size of any order after an order is placed now today, trading 212 have updated clause 10.8.

In the same section, it used to say once accepted by us, your order cannot be amended or cancelled by you et cetera, et cetera, and the problem was that, together with that new clause, it meant that in theory, trading212 could change or amend any order. They feel like because they feel like it only you couldn't change or cancel the order. Now that same clause says once accepted by us. An order or pending order cannot be amended.

This is a small change, but has very big implications. Now they are saying that they can't just go and change your order, just as well as you they do further down, say we reserve the right to amanda, cancel your order or pending order due to market circumstances, but this makes far more sense. Let's say the stock you're trading is halted in the stock market or a whole stock market is halted because there's a crash or whatever other reason, there are circumstances in those cases. Maybe your orders won't go through, so they fixed that one right thumbs up.

I also highlighted in much the clause 10.1 had an issue we may in our reasonable discretion, refuse to accept any order instruction from you, or we may accept your order subject to certain conditions, or we may acting reasonably refuse to proceed with an order that we have Accepted this didn't sound good, it sounded like trading212 was saying that they can refuse to execute your orders just if they felt like it, and this new change to clause 10.8. That i just mentioned also addresses that issue as well. It says that training 202 can't go and edit or cancel your order unless there are exceptional, market-based circumstances double thumbs up great. They have also clarified a number of other sections which makes them better.

The section about collateral when your shares are lent out is more clear. I like that a lot and they've provided a lot of extra sections explaining the withdrawal process on your cash. I actually really like this section now. It gives you protection from somebody hacking into your account and withdrawing your money to their own account.

This is a good thing. This is good. It is good that they are taking these precautionary steps. Section 5.14 has another very good set of word change.

He used to say we reserved the right to place a sell-only limitation in the following cases, but not limited to, and this has changed so we reserve the rights to immediately place a sell-only limitation in the following cases. This is important again. It means that it is limited to the reasons provided and trading 202 can't just place a sell-only restriction in your account for no reason which the previous terms kind of let them do now aside from fixing a few typos, there's only one other change in these t's And c's that i think, is material, and this is the bad one. There is one other bad thing that i'm going to cover in just a second, but let's look at this one.

First, the clause that we're talking about is 13.10. This clause has not changed much, but the changes trading two and two have made are really important. Listen up. This clause says that your investments may be held with a custodian and it used to say we may decide that it is in your best interest for your investments held with us to be registered or recorded in our name or in the name of the person.

Who is a custodian for the purposes of fca rules and if it is not feasible for us to do this, then blah blah blah? Now it says it may not be possible to register your investments in your name, the name of the nominee or other relevant third party and where we have determined that it is in your best interests, or it is not feasible to do. Otherwise. Your investments may be registered or recorded in our name or in the name of the person who is the custodian insofar as is permitted by the applicable fca rules. This is a huge change.

It previously said that they may hold your shares with a custodian if they think it is in your best interest. Now they say that if they decide that they can't, for whatever reason, register the shares in your name, then your shares will be held by the custodian in trading to one two's name or in the name of the custodian and those shares that you buy. On the platform with your money, the shares that are supposedly owned by you and held by trading 22 on your behalf and should be protected by fscs for up to 85 000 pounds are, let me quote: hey your investments may not be segregated and separately identifiable from The investments of the firm or custodian, in whose name your investments are registered and b as a consequence in the event of failure, your investments may not be as well protected from claims made on behalf of our general creditors. You should note that when we arrange for a third party to hold your investments overseas, there may be different settlement, legal and regulatory requirements than those applied in the uk.

Now this is incredibly worrying. They are saying that if trading 212 or the custodian run into any kind of trouble and fail, then your investments, your assets, your shares that you hold with them may be sold and paid out to creditors before you are able to get them. People trading 212 owes money to or people the custodian owes money to may be able to get your shares before you. So, in that case, you won't be able to get your investments back, but some random people that trading two and two of the custodian owe money to will be able to get it instead.

Now i am no lawyer, but that sounds incredibly at odds with fca's requirements and fscs protection. Regulated companies like trade into one two have a legal obligation to hold customer funds and assets in a fully segregated manner, so that if the company fails, those assets are not part of the company's assets. Those companies are not part of any company's assets. Precisely so that your shares cannot be sold to pay our creditors so that your money cannot be paid out to creditors, because it is yours and they are holding it on your behalf.

So here in trading 202's new terms, conditions, they are saying the opposite. Literally, the exact quote is, as a consequence, in the event of a failure. Your investments may not be as well protected from claims made on behalf of our general creditors, and i hope the trainings want to come out and clarify this point or fix this, because this is extremely important as someone who holds most of their investments with trading 212. Me this is a massive concern.

Now recently, trains 1 2 have actually injected a load of cash into the business. The two founders have just put in 13.75 million pounds into the company and that's on top of six million pounds that they put into the company. Just two months ago, in june, so over the last few weeks, they've put in about 20 million pounds into the business compared to just 4.8 million before then. So that should give you some reassurance, and hopefully that means that the risk of training 202 going under is significantly reduced, and that should be better.

Given what i just said. They have cash to support themselves to keep on going for quite a long while, based on their current expenditure, also trading 212 have just reopened to customers from the eu and i'm guessing that. After releasing these new terms conditions, they may also be reopening to uk customers. Very soon as well, because that would make sense - and that may mean that those extra customers will flow extra cash into the company, so they'll be making some profits because those customers gon na be making deposits buying shares.

And hopefully that will mean that the company is not going to go under, but here is the second big problem that i have when training 212 closed applications for new accounts in january they said that it was for technical reasons. They said they were improving their software. They needed to scale because you know there were so many customers and that required some time for them to go and increase their capacity and that didn't sound, very probable at all, especially as i've worked with tech and financial services products in the past. It didn't really sound like that was the whole story.

I actually asked the question in a video straight after they did it. Here's the thing so if they had all these people join and they had to go and put up several million pounds immediately at the point when they're joining. Is this pointing uh to a potential cash flow problem? And i got a very strong rebuttal from trading to one two themselves. I got contacted by trading 212 and on their public forum.

They posted a response which said there are no cash flow or liquidity issues or concerns whatsoever. And yet here we are. We have waited for over six months, with no new cans being able to register with no updates from 20212 as to what's going on, and in the last few weeks they have deposited 20 million pounds into trading to unto his bank account. It could be the case, maybe that it took them some time to privately raise that 20 million pounds before depositing it in yeah.

Maybe about six months of time and at the end of 2019, which is the latest accounts they have, they did have five million pounds. Apparently, in the bank account and according to those same accounts, the company has been profitable and that's what they've been saying all along. But, interestingly enough, almost exactly as soon as they deposited that money into trading 212. They started processing european account backlog and then they opened european accounts and now, a few days later, they're publishing these new uk terms and conditions and maybe reopening to uk customers as well.

It's funny timing that right, it's a bit of a coincidence. So is it a huge coincidence or did trading 212 need cash? Was there a cash flow problem? Well, i don't know, but i'm not sure how i feel about these developments. I'm not sure how i feel about the way that this is looking. I do not like the fact that their terms and conditions are telling me that my shares on trading two on two may be sold off to clear trading to unto's debt or the debt of a custodian that i have no idea who it is.

I don't like that they publicly dismiss valid questions, and yet six months later it looks like those questions were maybe more valid than trading toronto would like to admit. I still have most of my investments with trading to one two, including in ices at the moment, but i am very seriously considering alternatives. Thank you so much for watching this video. I really appreciate it.

I hope you found this useful and, as always i'll see you guys later, you.